Privacy Policy
This Privacy Policy explains to you the nature, scope and purpose of the processing of personal data
(hereinafter referred to as "Data") within our online offer and the associated websites, functions and
contents as well as external online presences, such as our Social Media Profile (hereinafter jointly
referred to as "online offer"). With regard to the terms used, such as "processing" or "person
responsible", we refer to the definitions in Art. 4 of the Basic Data Protection Ordinance (DSGVO).
Responsible
Sherzod Haydarov
Düsseldorfer Str. 60
33647 Bielefeld
GERMANY
s.haydarov@sparsecreations.com
Managing Director:Bernd Volkmer
Contact data protection officer: s.haydarov@sparsecreations.com
Types of processed data:
- Usage data (e.g., visited websites, interest in content, access times).
- Meta/communication data (e.g., device information, IP addresses).
Categories of affected persons
Visitors and users of the online offer (hereinafter also referred to in summary as "users").
Purpose of processing
- Provision of the online offer, its functions and contents.
- Answer contact requests and communicate with users.
- Security measures.
- Range measurement/marketing
Terms used
"Personal data" are all information relating to an identified or identifiable natural person (hereinafter
"data subject"); a natural person is regarded as identifiable who, directly or indirectly, in particular
by assignment to an identification such as a name, to an identification number, to location data, to an
online identification (e.g.B. Cookie) or to one or more special characteristics that are an expression
of the physical, physiological, genetic, psychological, economic, cultural or social identity of this
natural person.
"Processing" means any operation or series of operations carried out with or without the aid of
automated procedures in connection with personal data. The term goes a long way and covers practically
every handling of data.
"Pseudonymisation" means the processing of personal data in such a way that the personal data can no
longer be attributed to a specific data subject without the use of additional information, provided that
this additional information is kept separately and is subject to technical and organisational measures
to ensure that the personal data are not attributed to an identified or identifiable natural person.
"Profiling" means any automated processing of personal data consisting in the use of such personal data
to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict
aspects relating to the work performance, economic situation, health, personal preferences, interests,
reliability, behaviour, location or relocation of that natural person.
"Responsible" means the natural or legal person, authority, institution or other body that alone or
together with others decides on the purposes and means of processing personal data.
"Processor" means a natural or legal person, authority, institution or other body processing personal
data on behalf of the controller.
Substantial legal bases
In accordance with Art. 13 DSGVO we inform you of the legal bases of our data processing. If the legal
basis is not mentioned in the data protection declaration, the following applies: The legal basis for
obtaining consents is Art. 6 para. 1 lit. a and Art. 7 DSGVO, the legal basis for processing for the
performance of our services and performance of contractual measures as well as for answering inquiries
is Art. 6 para. 1 lit. b DSGVO, the legal basis for processing to fulfil our legal obligations is Art. 6
para. 1 lit. c DSGVO, and the legal basis for processing to protect our legitimate interests is Art. 6
para. 1 lit. f DSGVO. In the event that the vital interests of the data subject or another natural
person require the processing of personal data, Article 6(1)(d) DSGVO serves as the legal basis.
Security measures
We take appropriate technical and organisational measures to ensure a level of protection appropriate to
the risk, taking into account the state of the art, the implementation costs and the type, scope,
circumstances and purposes of processing as well as the different probability of occurrence and severity
of the risk to the rights and freedoms of natural persons, in accordance with Art. 32 DSGVO.
Such measures shall in particular include ensuring the confidentiality, integrity and availability of
data by controlling physical access to the data, as well as the access, input, transmission, security of
availability and its separation. Furthermore, we have established procedures to ensure the exercise of
rights of data subjects, deletion of data and reaction to endangerment of data. Furthermore, we already
consider the protection of personal data during the development or selection of hardware, software and
procedures, in accordance with the principle of data protection through technology design and data
protection-friendly presettings (Art. 25 DSGVO).
Cooperation with contract processors and third parties
If we disclose data to other persons and companies (contract processors or third parties) within the
scope of our processing, if we transfer them to them or otherwise grant them access to the data, this is
only on the basis of a legal permission (e.g.B. if a transmission of the data to third parties, such as
payment service providers, is required for contract fulfilment pursuant to Art. 6 para. 1 letter b
DSGVO), you have consented, a legal obligation provides for this or on the basis of our legitimate
interests (e.g. when using agents, web hosts, etc.).
If we commission third parties with the processing of data on the basis of a so-called "order processing
contract", this is done on the basis of Art. 28 DSGVO.
Transmissions to third countries
If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area
(EEA)) or if this occurs in the context of the use of third-party services or disclosure or transmission
of data to third parties, this will only take place if it occurs in order to fulfil our (pre)contractual
obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our
legitimate interests. Subject to legal or contractual permissions, we process or leave the data in a
third country only if the special requirements of Art. 44 ff. Process DSGVO. This means, for example,
processing is carried out on the basis of special guarantees, such as the officially recognised
determination of a data protection level corresponding to the EU (e.g. for the USA by the "Privacy
Shield") or compliance with officially recognised special contractual obligations (so-called "standard
contractual clauses").
Rights of the data subjects
You have the right to request confirmation as to whether the data concerned are processed and to request
information about this data as well as further information and a copy of the data in accordance with
Art. 15 DSGVO.
They have correspondingly. In accordance with Article 16 of the DSBER, you have the right to request the
completion of data concerning you or the correction of inaccurate data concerning you.
In accordance with Art. 17 DSGVO, you have the right to demand that relevant data be deleted immediately
or, alternatively, to demand a restriction on the processing of the data in accordance with Art. 18
DSGVO.
You have the right to request that the data concerning you that you have provided to us be received in
accordance with Art. 20 DSGVO and to request its transmission to other persons responsible.
In accordance with Art. 77 DSGVO, they also have the right to file a complaint with the competent
supervisory authority.
Right of revocation
You have the right to revoke granted consents according to art. 7 para. 3 DSGVO with effect for the
future
Right of revocation
You can object to the future processing of the data concerning you according to art. 21 DSGVO at any
time. The objection may be lodged in particular against processing for direct marketing purposes.
Cookies and right of objection for direct mail
"Cookies" are small files that are stored on users' computers. Different data can be stored within the
cookies. A cookie is primarily used to store information about a user (or the device on which the cookie
is stored) during or after his or her visit to an online offer. Temporary cookies, or "session cookies"
or "transient cookies", are cookies that are deleted after a user leaves an online offer and closes his
browser. In such a cookie, for example, the content of a shopping basket in an online shop or a login
status can be stored. Cookies are referred to as "permanent" or "persistent" and remain stored even
after the browser is closed. For example, the login status can be saved when users visit it after
several days. Likewise, the interests of users used for range measurement or marketing purposes may be
stored in such a cookie. Third-party cookies" are cookies that are offered by providers other than the
person responsible for operating the online offer (otherwise, if they are only its cookies, they are
referred to as "first-party cookies").
We may use temporary and permanent cookies and clarify this within the framework of our data protection
declaration.
If users do not want cookies to be stored on their computer, they are asked to deactivate the
corresponding option in the system settings of their browser. Stored cookies can be deleted in the
system settings of the browser. The exclusion of cookies can lead to functional restrictions of this
online offer.
A general objection to the use of cookies used for online marketing purposes can be declared for a large
number of services, especially in the case of tracking, via the US site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. Furthermore, the
storage of cookies can be achieved by deactivating them in the browser settings. Please note that in
this case not all functions of this online offer can be used.
Deletion of data
The data processed by us are deleted or restricted in their processing in accordance with Art. 17 and 18
DSGVO. Unless expressly stated in this data protection declaration, the data stored by us will be
deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict
with any statutory storage obligations. If the data are not deleted because they are necessary for other
and legally permissible purposes, their processing is restricted. This means that the data is blocked
and not processed for other purposes. This applies, for example, to data that must be retained for
commercial or tax reasons.
According to legal requirements in Germany, the storage is carried out in particular for 10 years in
accordance with §§ 147 para. 1 AO, 257 para. 1 no. 1 and 4, para. 4 HGB (books, records,
management reports, accounting documents, trading books, documents relevant for taxation, etc.) and 6
years in accordance with § 257 para. 1 no. 2 and 3, para. 4 HGB (commercial letters).
In accordance with legal requirements in Austria, storage is carried out in particular for 7 years in
accordance with § 132 (1) BAO (accounting documents, receipts/invoices, accounts, receipts,
business papers, statement of income and expenses, etc.), for 22 years in connection with real estate
and for 10 years for documents in connection with electronically provided services, telecommunications,
radio and television services which are provided to non-entrepreneurs in EU member states and for which
the Mini-One-Stop-Shop (MOSS) is used.
When contacting us (e.g. by contact form, e-mail, telephone or via social
media), the user's details for processing the contact request and its processing pursuant to Art. 6
para. 1 lit. b. (in the context of contractual/pre-contractual relationships), Art. 6 para. 1 lit.
f. (other requests) DSGVO. User information can be stored in a customer relationship management
system ("CRM system") or comparable request organization.
We delete the requests if they are no longer necessary. We review this requirement every two years;
the statutory archiving obligations also apply.
Hosting and emailing
The hosting services we use serve to provide the following services:
Infrastructure and platform services, computing capacity, storage space and database services,
e-mail delivery, security services and technical maintenance services that we use for the purpose of
operating this online offer.
We or our hosting provider process inventory data, contact data, content data, contract data, usage
data, meta- and communication data of customers, interested parties and visitors of this online
offer on the basis of our legitimate interests in an efficient and secure provision of this online
offer according to Art. 6 Para. 1 lit. f DSGVO in conjunction with. Art. 28 DSGVO (conclusion of
order processing contract).
Google Analytics
We rely on our legitimate interests (i.e. interest in the analysis,
optimization and economic operation of our online offer within the meaning of Art. 6 Para. 1 lit. f.
DSGVO) Google Analytics, a web analysis service of Google LLC ("Google"). Google uses cookies. The
information generated by the cookie about the use of the online offer by users is generally
transferred to a Google server in the USA and stored there.
Google is certified under the Privacy Shield Agreement and thereby offers a guarantee to comply with
European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
Google will use this information on our behalf to evaluate the use of our online offer by users, to
compile reports on the activities within this online offer and to provide us with further services
associated with the use of this online offer and the use of the Internet. Pseudonymous user profiles
can be created from the processed data.
We use Google Analytics only with IP anonymization enabled. This means that Google will reduce the
IP address of users within Member States of the European Union or in other states party to the
Agreement on the European Economic Area. Only in exceptional cases will the full IP address be
transmitted to a Google server in the USA and shortened there.
The IP address transmitted by the user's browser is not merged with other Google data. Users can
prevent the storage of cookies by setting their browser software accordingly; users can also prevent
Google from collecting the data generated by the cookie and relating to their use of the online
offer and the processing of this data by Google by downloading and installing the browser plug-in
available under the following link: http://tools.google.com/dlpage/gaoptout?hl=en.
Further information on data use by Google, possible settings and objections can be found in Google's
data protection declaration (https://policies.google.com/technologies/ads)
and in the settings for the display of advertisements by Google (https://adssettings.google.com/authenticated).
Users' personal data will be deleted or made anonymous after 14 months.
Google Adsense with non-personalized ads
We use on the basis of our legitimate interests (i.e. interest in the
analysis, optimization and economic operation of our online offer within the meaning of Art. 6 Para.
1 lit. f. DSGVO) the services of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043,
USA, ("Google").
Google is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with
European data protection law
(https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
We use the AdSense service, which is used to display ads on our website and pay us for their
insertion or other use. For these purposes, usage data such as the click on an advertisement and the
IP address of the user are processed, whereby the IP address is shortened by the last two digits.
Therefore, the processing of the user's data is pseudonymised.
We use Adsense with non-personalized ads. The ads are not displayed on the basis of user profiles.
Non-personalized ads are not based on previous user behavior. Targeting uses contextual information,
including rough geographic targeting (e.g. at the local level) based on the current location, the
content of the current website or app, and current search terms. Google prevents any personalized
targeting, including demographic targeting and targeting based on user lists.
Further information on data use by Google, possible settings and objections can be found in Google's
data protection declaration (https://policies.google.com/technologies/ads)
and in the settings for the display of advertisements by Google (https://adssettings.google.com/authenticated).
We maintain online presence within social networks and platforms to
communicate with customers, prospects and users active there and to inform them about our services.
When accessing the respective networks and platforms, the terms and conditions and the data
processing guidelines of their respective operators apply.
Unless otherwise stated in our privacy policy, we process the data of users who communicate with us
within social networks and platforms, e.g. write articles on our websites or send us
messages.
Integration of services and content of third parties
We set within our online offer on the basis of our legitimate interests
(i.e. interest in the analysis, optimization and economic operation of our online offer in the sense
of Art. 6 Abs. 1 lit. f. DSGVO) content or service offerings of third parties to incorporate their
content and services, such as videos or fonts (hereinafter uniformly referred to as "content").
This always presupposes that the third party providers of this content perceive the IP address of
the users, since without the IP address they could not send the content to their browser. The IP
address is therefore required for the display of this content. We make every effort to use only
those contents whose respective providers use the IP address only for the delivery of the contents.
Third-party providers may also use so-called pixel tags (invisible graphics, also known as "web
beacons") for statistical or marketing purposes. Pixel tags" can be used to evaluate information
such as visitor traffic on the pages of this website. The pseudonymous information may also be
stored in cookies on the user's device and may include technical information about the browser and
operating system, referring websites, visiting time and other information about the use of our
online offer, as well as be linked to such information from other sources.
Google Fonts
We include the fonts ("Google Fonts") from Google LLC, 1600 Amphitheatre
Parkway, Mountain View, CA 94043, USA. Privacy Policy: https://www.google.com/policies/privacy/,
Opt-Out: https://adssettings.google.com/authenticated.
Use of Facebook Social Plugins
We use on the basis of our legitimate interests (i.e. interest in the
analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para.
1 lit. f. DSGVO) Social Plugins ("Plugins") of the social network facebook.com, which is operated by
Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland ("Facebook").
This may include, for example, content such as images, videos or texts and buttons with which users
can share content from this online offer within Facebook. The list and appearance of Facebook Social
Plugins can be viewed here: https://developers.facebook.com/docs/plugins/.
Facebook is certified under the Privacy Shield Agreement and thereby offers a guarantee to comply
with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).
When a user calls up a function of this online offer that contains such a plugin, his device
establishes a direct connection to the Facebook servers. The content of the plugin is transmitted by
Facebook directly to the user's device and integrated into the online offer. The processed data can
be used to create user profiles. We therefore have no influence on the amount of data Facebook
collects with the help of this plugin and therefore inform users according to our level of
knowledge.
By integrating the plugins, Facebook receives information that a user has called up the
corresponding page of the online offer. If the user is logged in to Facebook, Facebook can assign
the visit to his Facebook account. When users interact with the plugins, such as pressing the Like
button or posting a comment, the information is sent directly from your device to Facebook and
stored there. If a user is not a member of Facebook, it is still possible for Facebook to obtain and
store their IP address. According to Facebook, only an anonymized IP address is stored in
Germany.
The purpose and scope of data collection and the further processing and use of the data by Facebook
as well as the relevant rights and setting options for the protection of users' privacy can be found
in the Facebook data protection information: https://www.facebook.com/about/privacy/.
If a user is a Facebook member and does not want Facebook to collect data about him via this online
offer and link it to his membership data stored on Facebook, he must log out of Facebook before
using our online offer and delete his cookies. Further settings and objections to the use of data
for advertising purposes are possible within the Facebook profile settings: https://www.facebook.com/settings?tab=ads
or via the US site http://www.aboutads.info/choices/ or the EU
site http://www.youronlinechoices.com/. The settings are
platform-independent, i.e. they are applied to all devices, such as desktop computers or mobile
devices.
Instagram
Functions and contents of the service Instagram, offered by Instagram
Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA, can be integrated within our online offer. This
may include, for example, content such as images, videos or texts and buttons that users can use to
share content from this online offering within Instagram. If the users are members of the Instagram
platform, Instagram can assign the call of the above contents and functions to the profiles of the
users there. Instagram Privacy Policy: http://instagram.com/about/legal/privacy/.
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Datenschutz-Generator.de by RA Dr. Thomas Schwenke